RBG-47869, Supplement to Request Extension of Enforcement Discretion Provided in Enforcement Guidance Memorandum 15-002 for Tornado-Generated Missile Protection Non-Conformances Identified in Response to Regulatory Issue Summary 2015-06, Tornado Miss

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Supplement to Request Extension of Enforcement Discretion Provided in Enforcement Guidance Memorandum 15-002 for Tornado-Generated Missile Protection Non-Conformances Identified in Response to Regulatory Issue Summary 2015-06, Tornado Missi
ML18151A692
Person / Time
Site: River Bend Entergy icon.png
Issue date: 05/31/2018
From: Schenk T
Entergy Operations
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
RBG-47869
Download: ML18151A692 (10)
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May 31,2018 Attn: Document Control Desk U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852-2738

SUBJECT:

Supplement to Request Extension of Enforcement Discretion Provided in Enforcement Guidance Memorandum 15-002 for Tornado-Generated Missile Protection Non-Conformances Identified in Response to Regulatory Issue Summary 2015-06, "Tornado Missile Protection" River Bend Station, Unit 1 Docket No. 50-458 License No. NPF-47

REFERENCES:

1. Entergy Nuclear Operations, Inc., RBG-47865, Submitted on May 10, 2018, Request to Extend Enforcement Discretion Provided in Enforcement Guidance Memorandum 15-002 for Tornado-Generated Missile Protection Non-Conformances Identified in Response to Regulatory Issue Summary 2015-06, "Tornado Missile Protection", dated December 7,2017 (ADAMS Accession Number ML18130A917)
2. NRC memorandum, Enforcement Guidance Memorandum 15-002, Revision 1: Enforcement Discretion for Tornado-Generated Missile Protection Non-Compliance, dated February 7,2017 (ADAMS Accession Number ML16355A286)
3. NRC meeting summary, Summary of May 23,2018, Public Teleconference Meeting with Entergy Nuclear Operations, Inc.,

Regarding Request to Extend Enforcement Discretion for Tornado-Generated Missile Non-Conformances at River Bend Station (EPID L-2018-LLL-0020), dated May 25, 2018 (ADAMS Accession No. ML18144A828)

Dear Sir or Madam:

In Reference 1, Entergy Operations, Inc. (EOI) submitted a request to extend the expiration date for the period of enforcement discretion provided for tornado-generated missile protection non-conformances in Enforcement Guidance Memorandum (EGM) 2015-002, "Enforcement Guidance Memorandum 15-002, Revision 1: Enforcement Discretion for Tornado-Generated Missile Protection Non-Compliance" (Reference 2).

As documented in Reference 3, the Nuclear Regulatory Commission (NRC) had a teleconference meeting with EOI on May 23,2018 to discuss the extension request. During

RBG-47869 Page 2 of 2 the meeting, the NRC noted sections in the Reference 1 submittal in which supplemental information would be needed. Based on this discussion, EOI is providing the supplemental information in the attachment.

This letter identifies no new commitments and no revisions to existing commitments.

TAS/twf ATTACHMENT: Supplemental Information for Request to Extend Enforcement Discretion for Tornado-Generated Missile Protection Non-Conformances for River Bend Station cc: (with Enclosure) u.S. Nuclear Regulatory Commission Attn: Ms. Lisa M. Regner, Project Manager 09-0-14 One White Flint North 11555 Rockville Pike Rockville, MD 20852 u.S. Nuclear Regulatory Commission Region IV 1600 East Lamar Blvd.

Arlington, TX 76011-4511 NRC Senior Resident Inspector Attn: Mr. Jeff Sowa 5485 U.S. Highway 61, Suite 1 St. Francisville, LA 70775 Public Utility Commission of Texas Attn: PUC Filing Clerk 1701 N. Congress Avenue P. O. Box 13326 Austin, TX 78711-3326 RBF1-18-0106

RBG-47869 Attachment Page 1 of 8 RBG-47869 Supplemental Information for Request to Extend Enforcement Discretion for Tornado-Generated Missile Protection Non-Conformances for River Bend Station

RBG-47869 Attachment Page 2 of 8 Supplemental Information for Request to Extend Enforcement Discretion for Tornado-Generated Missile Protection Non-Conformances for River Bend Station In Reference 1, Entergy Operations, Inc. (EOI) requested an extension of the expiration date for the period of enforcement discretion provided for tornado-generated missile protection non-conformances in Enforcement Guidance Memorandum (EGM) 2015-002, "Enforcement Guidance Memorandum 15-002, Revision 1: Enforcement Discretion for Tornado-Generated Missile Protection Non-Compliance" (Reference 2).

As documented in Reference 3, the Nuclear Regulatory Commission (NRC) held a teleconference meeting with EOI on May 23,2018 to discuss the extension request.

During the meeting, the NRC noted sections of the Reference 1 submittal in which supplemental information would be needed. Specifically, the NRC discussed the following topics:

1. A more detailed description of the three non-conforming conditions (NCCs) identified by EOI in Reference 1 and the potential loss of safety function associated with those components.
2. A more detailed description of the initial and long-term compensatory measures takes for the three NCCs identified in Reference 1. Any interim and long-term actions taken or planned to complete repairs of the NCCs should also be included.
3. A description of the long-term comprehensive measures and an evaluation of the effectiveness of those compensatory measures.
4. An alternate corrective action to the tornado missile risk evaluator (TMRE).

Discussion Topic Number 1 A more detailed description of the three non-conforming conditions (NCCs) identified by EOI in Reference 1 and the potential loss of safety function associated with those components.

Discussion Topic Number 1 Supplemental Information In response to Regulatory Information Summary (RIS) 2015-06, "Tornado Missile Protection,"

Entergy has taken action to identify potential vulnerabilities in tornado missile protection at River Bend Station (RBS). During walk downs associated with the Tornado Missile Protection (TMP) project, the following vulnerabilities and associated safety related equipment have been identified.

The following system acronyms will be used in the remainder of this document

RBG-47869 Attachment Page 3 of 8 SBCT - Standby Cooling Tower UHS - Ultimate Heat Sink CR-RBS-20 18-02687:

In the Emergency Diesel Generator (EDG) Building:

DGB-COND-3A (Conduit Penetration) - East wall and north of Column 4, EI. 98'-0".

Affected Structure System or Component (SSC):

o Service Water Primary Pipe SWP-008-089 and SWP-008-090 associated with Division (DIV) I EDG Jacket Water Cooling.

o Emergency Diesel Generator Fuel Oil Transfer Piping EGF-750-013, EGF 750-012, and EGF-150-014, a" associated with Fuel Oil Transfer to DIV I EDG.

o DIV I Fuel Oil Day Tank EGF-TK2A.

DGB-COND-3B (Conduit Penetration) - East wall and north of Column 2, EI. 98'-0".

Affected SSCs:

o DIV" Fuel Oil Day Tank EGF-TK2B.

o Fuel Oil Transfer Pipe EGF-150-029, associated with Fuel Oil Transfer to the DIV" EDG.

o Pipe SWP-008-092 and Pipe SWP-008-091 are return/supply service water lines to the DIV " EDG Jacket Cooling Water Heat Exchanger.

o Pipe HVP-030-009 is Air Intake to the DIV " EDG DGB-COND-3C (Conduit Penetration) - East wall and north of Column 3, EI. 98'-0".

Affected SSCs:

o Pipe HVP-024-018 and Pipe HVP-024-006 are associated with DIV III EDG Air Intake DGB-1 D2W07 (Conduit Penetration) & DGB-5 (Pipe Penetration) - North wall and east of Column DE, EI. 98'-0". Affected SSCs:

o Pipe HVP-030-010 and HVP-024-011, DIV " EDG Air Supply and Exhaust piping.

o EGF-150-029 and EGF-750-027 are Fuel Oil Transfer piping to the DIV "

EDG.

o SWP-008-092 and SWP-008-091 is associated with DIV " Jacket Cooling Water Heat Exchanger.

o DIV II Air Start Air Receiver Tank.

o DIV" Diesel Generator EGS-EG1 B DGB-1 D2W11 (Conduit Penetration) - North wall and east of Column DE, EI. 98'-0".

Affected SSCs:

o Electrical Equipment (SCV-XD15B1, SCV-XD15A1, SCV-PNL 15A1, SCV-PNL 15B1); 1-JB0235 (Instrumentation cable 1EGADBX402 is routed from the tachometer to ERIS metering for division 2 DG frequency and Instrumentation cable 1EGFBBX401 provides fuel oil day storage tank 2B level signals from EGF-LT16B to EGF-LlX16B in EGS-PNL3B) o DIV" EDG ventilation fan and damper, HVP-FN2B and HVP-DMP9B.

RBG-47869 Attachment Page 4 of 8 o DIV II Jacket Water Cooling Piping SWP-008-092 and SWP-008-091 DGB-6 (Pipe Penetration) & DGB-7 (Pipe Penetration) - North wall and west of Column DE, EI. 98'-0". Affected SSCs:

o Electrical Equipment (EHS-MCC15B, EGS-PNL 1B, EGS-PNL3B, EGS-PNL2B) o DIV II Jacket Cooling Water Piping (SWP-008-092, SWP-008-091)

In conclusion, the documented vulnerabilities can render a" 3 Station Emergency Diesel Generators inoperable, thus requiring the station to take actions to shut down in accordance with Technical Specification (TS) Limiting Condition for Operation (LCO) 3.0.3.

CR-RBS-2018-02768:

In the Control Building:

Two electrical cable tray penetrations enter through two adjacent blockouts in the south wall of the Control Building above the Division II Remote Shutdown Room. Location: South Wall and east of Column CD, EI. -108'-0". Affected SSCs:

o Panel EJS-SWG1B - STANDBY SWGR RM 1B 480V SWG1B o Panel ENB-SWG01B - STANDBY BUS B 125 VOLTS DIRECT CURRENT SYS SWGR 01B o Panel EHS-MCC14B - STANDBY SWGR RM 1B MCC14B o Panel EHS-MCC8B - STANDBY SWGR RM 1B MCC8B o Panel ENS-SWG1B - 4160V STANDBY SWGR BUS 1B This documented vulnerability can render the following major safety related components inoperable:

(Most Limiting) Division II DC electrical power distribution subsystem which would place the station in Technical Specification 3.8.9, Distribution Systems-Operating, condition C. The required action would be to restore the DC electrical power distribution subsystem to operable status in 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> OR be in Mode 3 in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> per condition 0 E12-PC0001B/C (Residual Heat Removal pumps Bravo and Charlie) which would place the station in Technical Specification 3.5.1, ECCS-Operating, condition C. The required action would be to restore one of the ECCS injection/spray subsystems to operable status 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in Mode 3 in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> per condition D.

SWP-P2B and SWP-P2D (Standby Service Water Pumps B and D) which would place the station in Technical Specification 3.7.1, Standby Service Water System and Ultimate heat Sink, condition G. The required action would be to restore the SSW subsystem to operable status in 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in Mode 3 in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> per condition H.

Division II Emergency Diesel Generator which would place the station in Technical Specification 3.8.1, AC Sources-Operating, condition C. The required action would be to restore the Diesel Generator to operable status in 14 days or bein Mode 3 in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> per condition G.

RBG-47869 Attachment Page 5 of 8 CR-RBS-2018-02775:

In the Standby Service Water Cooling Tower:

Door SP098-01 or SS098-01, 3' x 7' opening. Location: Southeast wall at Stairwell, EI. 98'-3 3/4" Vulnerable SSCs:

o Division I Cable Trays 1TH202R, 1TK202R, 1TC204R, 1TX204R, 1TH203R, 1TK203R, 1TC205R, and 1TX205R.

o Division I Service Water Piping SWP-030-27, SWP-030-110, SWP-003-108, and SWP-030-217.

The major safety related components affected by the DIV I Cable Trays are:

Standby Service Water Pump A Standby Service Water Pump C All DIV I SBCT fans Multiple DIV I SSW Motor Operated Valves This condition would place the station in Technical Specification 3.7.1, SSW System and UHS, condition G. The required action would be to restore the SSW subsystem to operable in 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in Mode 3 in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> per condition H.

Discussion Topic Number 2 A more detailed description of the initial and long-term compensatory measures taken for the three NCCs identified in Reference 1. Any interim and long-term actions taken or planned to complete repairs of the NCCs should also be included.

Discussion Topic Number 2 Supplemental Information As an interim action to mitigate potential consequences of the postulated vulnerabilities, the Abnormal Operating Procedures (AOPs) would be used. The Licensed Operators are trained to take action using the AOPs if a tornado missile damages the identified non-conforming components. These AOPs are part of the Initial and Continuing Licensed Operator Training Program. Training verifications are performed at the beginning of each shift cycle to verify that all training requirements are up-to-date. Specifically, the following AOPs provide actions to mitigate the postulated events:

Standby Diesel Generators AOP-0050, Station Blackout, provides operators with instruction in the event of a loss of all offsite power combined with a failure of the Standby Diesel Generators to start and/or supply their emergency buses.

AOP-0065, Extended Loss of AC Power, provides guidance to operators in response to a Beyond-Design-Basis External Event that causes a loss of all offsite and onsite AC power expected to last greater than one hour.

RBG-47869 Attachment Page 6 of 8 Standby Service Water AOP-0016, Loss of Standby Service Water, provides operators with actions to take in the event of a loss of Standby Service Water.

Residual Heat Removal AOP-0051, Loss of Decay Heat Removal, provides instructions to ensure adequate decay heat removal capability exists for fuel within reactor vessel and for irradiated fuel in the containment or spent fuel pools.

DC Electric Power AOP-0014, Loss of 125 VDC, provides operators with instruction in the event 125 VDC is lost to one or more buses.

Control Building Ventilation AOP-0060, Loss of Control Building Ventilation, provides operators with instructions necessary to mitigate the loss of all Control Building Ventilation.

The operators maintain awareness of the tornado-generated missile protection non-conformances by reviewing the Main Control Room Logs every shift. A log entry has been added to the Main Control Room Log (and is carried over to every shift) that identifies the non-conformances and requires a brief of the compensatory actions to be performed every shift.

Operator actions to address plant conditions resulting from the tornado-generated missile protection non-conformances are contained within plant operating procedures, as discussed above. Operator awareness of these procedural actions is ensured via initial and continuing operator training, which includes reviews of procedural guidance for acts of nature.

In addition RBS is in compliance with NRC Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Reference 5). This Order directed licensees to develop and implement (FLEX) strategies and guidance to maintain or restore core cooling, containment cooling, and spent fuel pool cooling capabilities in the event of a beyond-design-basis external event in which AC power and normal access to the ultimate heat sink are lost. The FLEX procedures and equipment would be available to address plant conditions resulting from the tornado missile protection non-conformances, in addition to the operator actions described in the procedural guidance above.

As a longer term measure River Bend Station has contracted an Engineering firm to perform the necessary Engineering Changes required to correct the identified non-compliances. WOs 502377,502844,502843 have been generated to complete the work and are expected to be complete by the end of July 2018. The planned scope of work is the following:

The six conduit and piping penetrations in the Emergency Diesel Generator Building will be filled with grout.

The two electric cable penetrations in the Control Building will be protected by anchoring a steel plate to the wall covering the penetration.

RBG-47869 Attachment Page 7 of 8 The cage outside of the Standby Cooling Tower door will be upgraded with heaver steel.

Discussion Topic Number 3 A description of the long-term comprehensive measures and an evaluation of the effectiveness of those compensatory measures.

Discussion Topic Number 3 Supplemental Information AOP-0029, Severe Weather Operation, directs operators to assess plant damage following a tornado event. As a long term comprehensive measure, the procedure was revised to identify the safety related components and systems that are potentially vulnerable to tornado missiles so that operating crews understand where the vulnerability is and are prepared to mitigate the consequences of an event by performing actions of the Abnormal Operating Procedure associated with the effected component or system. The revision also directs operators to make a damage assessment of the vulnerable components and systems a priority. However, the revision did not place any time requirements on the operating crew. The added actions will be prioritized by the operating crew and be performed as soon as possible but not interfere with previously existing emergency procedures. The long-term compensatory measures that were put in place will have no impact on the operating crew's ability to respond to a design basis accident in accordance with previously established emergency procedures.

These long-term compensatory measures are in accordance with EGM 15-002, Rev. 1 and Interim Staff Guidance DSS-ISG-2016-01 and will remain in place until the non-conformances are resolved.

Discussion Topic Number 4 An alternate corrective action to the tornado missile risk evaluator (TMRE).

Discussion Topic Number 4 Supplemental Information As discussed in the response to Discussion Topic Number 2 above, Entergy's current plans are to resolve the identified non-conformances with modifications. But if this is not achieved, as part of River Bend's long term comprehensive compensatory measure effort, the site has identified probabilistic analysis for our tornado region that determines a bounding 20 square foot opening has a tornado missile strike probability of 2.44E-8 per year which is smaller than the 10E-7 per year outlined in the Standard Review Plan NUREG-0800 Section 2.2.3 (Revision 6). This calculation was performed using the EPRI Tornado Missile Simulation and Design Methodology (TORMIS) Volume 1 (Reference 7). As part of River Bend's ultimate resolution of tornado missile vulnerabilities and as an alternative to Tornado Missile Risk Evaluator (TMRE), an LAR submittal to the NRC to implement the TORMIS methodology as a probabilistic defense of tornado missiles will be evaluated. The analysis performed up to this point shows a risk level that meets the NRC's frequency criteria, and River Bend believes there is an alternative path to long term resolution with the NRC's approval of an amendment to allow for TORMIS methodology to be employed at River Bend Station.

RBG-47869 Attachment Page 8 of 8 References

1. Entergy Nuclear Operations, Inc., RBG-47865, Request to Extend Enforcement Discretion Provided in Enforcement Guidance Memorandum 15-002 for Tornado-Generated Missile Protection Non-Conformances Identified in Response to Regulatory Issue Summary 2015-06, "Tornado Missile Protection," dated December 7,2017 (ADAMS Accession Number ML18130A917)
2. NRC memorandum, Enforcement Guidance Memorandum 15-002, Revision 1:

Enforcement Discretion for Tornado-Generated Missile Protection Non-Compliance, dated February 7,2017 (ADAMS Accession Number ML16355A286)

3. NRC meeting summary, Summary of May 23, 2018, Public Teleconference Meeting with Entergy Nuclear Operations, Inc., Regarding Request to Extend Enforcement Discretion for Tornado-Generated Missile Non-Conformances at River Bend Station (EPID L-2018-LLL-0020), dated May 25,2018 (ADAMS Accession No. ML18144A828)
4. NRC Interim Staff Guidance DSS-ISG-2016-01, Clarification of Licensee Actions in Receipt of Enforcement Discretion Per Enforcement Guidance Memorandum EGM 15-002, "Enforcement Discretion for Tornado-Generated Missile Protection Noncompliance, "Revision 1, dated November 2017 (ADAMS Accession Number ML17128A344)
5. EOlletter, RBG-47618, Notification of Full Compliance with NRC Order EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design-Basis External Events," dated September 29, 2015 (ADAMS Accession No. ML15292A508)
6. NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition, Section 2.2.3, Revision 3.
7. Tornado Missile Simulation and Design Methodology, Volume 1: Simulation Methodology, Design Applications, and TORMIS Computer Code.
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